On August 16 New York State Association of Criminal Defense Lawyers (NYSACDL) of which our partner Steven Epstein, who is a nationally known DWI defense expert serves as president, submitted public comments regarding the Department of Motor Vehicles’ Proposed Point System and Licensing After Revocation Action. From the Letter: The proposed regulations reach far beyond the regulatory authority granted to the Department and it tramples upon the legislature’s authority and purview in violation of the separation of powers doctrine.
Instead of seeking “to establish a system” where one already exists, the Action is expanding the punitive reach of the Department’s jurisdiction without legislative authority to do so and engaging in legislative policy making beyond its statutory authority.
The 2024 DMV proposed regulations if implemented would unduly impact poor and underserved communities.
